What Happened A recent disclosure in the U.S. District Court for the Middle District of Tennessee is causing speculation as to what position the IRS may take on the taxable status of tokens created through proof-of-stake consensus mechanisms. The case, Jarrett v. United States, Case No. 3:21-cv-00419 (M.D.Tenn. filed May 26, 2021), was brought by a Tennessee couple seeking a tax refund after declaring $9,407 worth of Tezos tokens as income in their 2019 tax returns.